Sean McCormack – MiMedx’s “New Market Initiatives Director” – was an instrumental figure in Advanced BioHealing’s kickback and bribery inducement scheme, which resulted in the largest settlement of a False Claims Act breach to date: US$350m settlement, and a US$600m+ write-down by Shire. At least 54 Advanced BioHealing alumnus have been identified by Viceroy within MiMedx’s sales force including at least 15 in senior employment positions.

A FOIA request was withheld by the Securities and Exchange Commission (SEC) suggesting MiMedx is the target of an undisclosed SEC enforcement investigation.

Former employees-turned whistleblowers accused MiMedx of aggressive channel-stuffing practices and improper revenue recognition policies. Their statement named many ex-Advanced BioHealing employees. Despite the fact these allegations having been withdrawn, Viceroy’s analysis found evidence supporting these claims in MiMedx’s financial accounts – there’s no smoke without fire.

MiMedx’s SAM compliance certification was filled out by Don Ayers, who was no longer employed by MiMedx at the time the forms were signed.